Part1-Colonial-Pipeline-Co-Emergency-Response-Plans-Southeast-Oct-2015.Pdf

Colonial Pipeline Company CONSISTENCY WITH CONTINGENCY PLANS Page 1 of 2 CONSISTENCY WITH THE NATIONAL CONTINGENCY PLAN The Emergency Response Plans submitted by Colonial Pipeline Com

C olonial P ipeline C ompany

Emergency Response Plans

Southeast Response Zone

Colonial Pipeline Company

SECTION 5 – LIST OF CONTACTS

5.01 Spill Management Team Roster Generic 5.02 HAZWOPER Trained Personnel Generic 5.03 District Wide Employee Phone List Local 5.04 Other Federal, State, and Local Agencies Local 5.05 Oil Spill Response Organizations (OSRO) Local 5.06 Pipeline Repair Contractors Local 5.07 Environmental Contractors Local 5.08 Aerial Recon Contractors Local 5.09 Other Emergency Response Equipment Suppliers Local 5.10 Vendor Support & Supplies Local 5.11 Airports & FBO’s Generic 5.12 Local Terminal Managers & Adjacent Pipelines Local 5.13 Local Emergency Care Facilities Local 5.14 USCG Captains of the Port Generic

SECTION 6 – TRAINING

6.01 Training Courses & Requirements Generic

SECTION 7 – EXERCISE PROCEDURES

7.01 Exercise Program Generic

7.02 Exercise Documentation Generic

7.02.01 Triennial Cycle Documentation Generic 7.02.02 Internal Notification Exercise Documentation – Group 4 Generic 7.02.03 Post Tabletop Exercise Evaluation Generic 7.02.04 Equipment Deployment Exercise Evaluation Generic 7.02.05 Equipment Deployment Exercise – Participants Generic 7.02.06 Equipment Deployment Exercise – Equipment Generic 7.02.07 Emergency Operating Procedures Exercise Evaluation Generic

SECTION 8 – RESPONSE PLAN REVIEW

8.01 Response Plan Review, Update Procedures, and Accountability Generic 8.02 Document Control Procedures Generic

SECTION 9 – EMERGENCY RESPONSE INFORMATION

9.01 Product Characteristics & SDS Sheets Generic 9.02 Response Strategies Generic 9.02.01 Air Monitoring Protocol Generic 9.03 Block Valve Locations Generic 9.04 Rectifier Locations Local 9.05 Environmentally Sensitive Areas Local 9.06 Water Intakes Local

Colonial Pipeline Company

CONSISTENCY WITH CONTINGENCY PLANS

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CONSISTENCY WITH THE NATIONAL CONTINGENCY PLAN

The Emergency Response Plans submitted by Colonial Pipeline Company for each of its three response zones will be reviewed and revised periodically to maintain consistency with applicable parts of the National Contingency Plan

CONSISTENCY WITH THE APPLICABLE AREA CONTINGENCY PLANS

The Emergency Response Plans submitted by Colonial Pipeline Company for each of its three response zones will be reviewed and revised periodically to maintain consistency with the Area Contingency Plans applicable to Colonial’s pipeline system

Applicable Area Contingency Plans administered by the U.S Coast Guard and EPA as well as their corresponding Colonial/PHMSA response zones are identified below:

CPC District PHMSA Response Zone Applicable ACP’s, GRP’s, & IACP’s

Sector Houston/Galveston MSU Port Arthur MSU Morgan City MSU New Orleans

EPA Region VI Regional IACP

Oil & Hazardous Substances Pollution Regional and Area Contingency Plan

EPA Region III

Inland Area Committee Plan

EPA Region III

Inland Area Committee Plan

USCG Sector Delaware Bay ACP USCG New York and New Jersey ACP USCG Upper Chesapeake ACP USCG Hampton Roads ACP

Colonial Pipeline Company

SOUTHEAST RESPONSE ZONE

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INFORMATION SUMMARY

Name and Address of Operator:

Colonial Pipeline Company

P O Box 1624 Alpharetta, GA 30009-9934 SIGNIFICANT & SUBSTANTIAL HARM

The volume of petroleum products transported by the Colonial Pipeline system (and the criteria set forth

in DOT49CFR§194.103) dictate that a release of oil at any point in any line segment could cause significant and substantial harm Therefore, all Response Zones are identified as having the potential for causing significant and substantial harm

DESCRIPTION OF RESPONSE ZONES

Colonial Pipeline Company has identified three response zones for its pipeline system Currently, these response zones correspond with the three operating districts of Colonial’s pipeline system The response zones for the entire pipeline system are listed according to PHMSA zone numbers and name of the Colonial operating area, including states and counties

WORST CASE DISCHARGE

(b) (6)(b) (6)

(b) (3), (b) (7)(F)

(b) (3), (b) (7)(F)

PHMSA Response Zone 802 Colonial Response Zone: Southeast

South Carolina Counties

Abbeville Aiken Anderson Cherokee Edgefield Greenville Greenwood Laurens McCormick Spartanburg York

Tennessee Counties Bradley Coffee Davidson Grundy Hamilton Knox Loudon Marion McMinn Monroe Rutherford

Alabama Counties Bibb Calhoun Cleburne Green Hale Jefferson Saint Clair Shelby Sumter Talladega Tuscaloosa

Georgia Counties Baker Barrow Bartow Bibb Carroll Catoosa Chattooga Clarke Clayton Cobb

Crawford Decatur Dekalb Dougherty Douglas Elbert Fayette Floyd Fulton Gwinnett Harralson Hart Henry Jackson Lamar Lee Macon Madison Mitchell Monroe Paulding Peach Richmond Schley Spalding Sumter Walker

North Carolina Counties Alamance Cabarrus Chatham Cleveland Cumberland Davidson Gaston Guilford Harnett Johnston Mecklenburg Rockingham Rowan Wake

Virginia Counties Danville Halifax Pittsylvania

Southeast District 01.03.00 Response Zone Overview Map Updated: October 2012

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Colonial Pipeline Company RESPONSE ZONE 802 – SOUTHEAST DISTRICT

Colonial Pipeline Company

STATEMENT OF SIGNIFICANT AND SUBSTANTIAL HARM

It has been determined that a pipeline rupture occurring in any line segment of the pipeline system

could cause significant and substantial harm based on the criteria listed below

Pipeline Diameters comprising the line segments

Southeast District 01.04.00 Statement of Significant and Substantial Harm Updated: December 2015

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Southeast District 01.05.00 Certification of Response Preparedness Updated: April 2016

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Colonial Pipeline Company

America’s Energy Lifeline

CERTIFICATION OF RESPONSE RESOURCES

Colonial Pipeline Company hereby certifies to the U.S Department of Transportation (DOT), Pipeline and

Hazardous Materials Safety Administration (PHMSA) that is has identified, and ensured by contract, or other means approved by PHMSA, the availability of private personnel and equipment to respond, in the maximum extent practicable to a worst case discharge or a substantial threat of such a discharge

This includes contracts with Oil Spill Removal Organizations (OSROs) in each of the operating Districts More information on Colonial’s OSRO, please refer to ERP Section 5.05.00 Oil Spill Removal Organizations –

OSROS For certification purposes for this plan, pertinent information includes:

Region 801 (Gulf Coast District-GCD)

ENVIRONMENTAL SAFETY & HEALTH CONSULTING SERVICES INC 51-08 10/01/10

Region 802 (Southeast District-SED)

Region 803 (Northeast District-NED)

Colonial Pipeline Company

WORST CASE DISCHARGE

ALIGNMENT MAP NUMBER:

USGS MAP NUMBER:

UPSTREAM ISOLATION LOCATION:

LEAK STATION NUMBER:

DOWNSTREAM ISOLATION LOCATION:

APPROXIMATE PHYSICAL LOCATION:

Construction / Operating Parameters

Dynamic discharge is the total fluid outflow at the rupture before the pipeline is shut down and the line segment containing the rupture is operationally isolated During this period, the pipeline flow rate could be much higher than its normal operating flow rate depending on the relative location of the rupture to the adjacent pumping stations This transient flow rate, however, cannot exceed the maximum capacity of pump units upstream of the rupture due to the limitation of horsepower installed and to the characteristic of turbo machinery Based on these parameters, an estimate of the dynamic discharge can be made by assuming the maximum capacity of the pumps being operated prior to the rupture, as the discharge flow rate for the period between rupture occurrence and pipeline shutdown

Static drain discharge is considered to be the total fluid outflow at the rupture location due to the difference

of elevations between the rupture and other high points on the pipeline except that isolated by either elevation or remote-controlled valves The fluid momentum and the siphoning effect, for practical purposes, can be ignored

The WCD for pipeline segments can be expressed as:

Vt = Vd +ΣVsWhere:

Vt = total WCD volume, in barrels

Vd = dynamic discharge volume, in barrels

Vs = static discharge volume, comprised of the gravity drain from both upstream and downstream segments based on the elevation profile, in barrels

(b) (7)(F), (b) (3)

(b) (7)(F), (b) (3)

(b) (3), (b) (7)(F)

Assumptions:

Scenario is a guillotine rupture (100% volume - out);

Following a line rupture, the pipeline segment that contains the rupture will be remotely shut down and isolated within three (3) minutes;

For the dynamic discharge calculation, the discharge flow rate will be the flow rate that the immediate upstream pump station is capable of; and

Except for the installed check valves and remotely controlled block valves, no further segment isolation is assumed by closing the manual isolation valves

The dynamic discharge component (Vd) is determined by multiplying the timeframe to operationally isolate the line segment by the design throughput:

Vd =

The static/gravity discharge component (Vs) is the gravity drain volume from both upstream and downstream segments based on the elevation profile in the Pipeline Simulation Software The volume excludes that which is isolated by either elevation or remote-controlled valves

HISTORICAL DISCHARGE COMPARISON

A review of historical releases from the Colonial system shows that the largest release volume in the Southeast Response Zone was 22,800 bbl which does not exceed either of the WCD estimates for the tankage or pipeline scenarios

Colonial Pipeline Company

WORST CASE DISCHARGE – SCENARIO

A Worst Case Discharge Response Scenario

Scenario Development

A worst-case discharge scenario involving breakout

for its proximity to an area where drainage away from the facility’s retention lakes is possible

is surrounded by an earthen secondary containment dike common to one other tank This dike has an average depth of twelve feet (12 ft.) and has more than sufficient capacity to contain the entire contents

of the tank

This scenario assumes a brittle fracture type failure similar to the Ashland Oil spill at Florette, PA on January 2, 1988 Statistics from the Ashland incident indicate that approximately 18% of the total volume spilled escaped secondary containment into the Monongahela River For planning purposes and this scenario, it is assumed that f distillate product (fuel oil or kerosene) will breach the dike and escape the secondary containment around

The has a series of catch basins, pipes, and ditches designed to divert watershed runoff and spills to the lakes The facility features two lakes in a valley between the two breakout tank clusters The lakes are designed with underflow outlets Product flowing into the lakes will float on the surface of the water and will have to accumulate to a height of more than 24” above high water mark before it will overflow across the dike and escape these containments

It is assumed that the spilled volume that escapes from the tank dike would initially flow overland in a westerly direction, bypass the on-site lake, and enter a small stream at the lake effluent that flows to the south

Time of Year/Weather

This scenario takes place in the month of January This month is chosen because it is when the ambient temperatures occur most frequently which are likely to allow a brittle fracture to occur The scenario begins at dusk

(b) (3), (b) (7)(F)

(b) (3), (b) (7)(F)

(b) (3), (b) (7)(F) (b) (3), (b) (7)(F)

Scenario weather calls for a wet weather (steady rain) with temperatures in the mid-30’s The rain will facilitate the down gradient movement of the product

Topography, Drainage, and Resources at Risk

Topography: The topography of the area in the tank farm is graded generally flat within the breakout tanks containment area is located at the southern-most point of Colonial’s storage facility The area proximate to the tank in question is bordered by Colonial’s property to the west and

to the south The area between the tank farm and is part of Colonial’s facility and is wooded, with heavy underbrush, undeveloped land The areas south of

have several industrial developments, community parks, and some residential areas Land is relatively level bisected by a wooded stream valley that is 20 to 30 feet lower than the adjacent developed areas

Drainage: For the purpose of this exercise, it is assumed that product would splash over the containment dike towards the west, flow overland in a down gradient, westerly direction for approximately 20 miles and then continue in a southerly direction for 20 miles, leaving Colonial’s property via a small, slow flowing stream that crosses under This stream is a tributary of

The released product will continue in a southerly flow within the creek for 60 miles to the crossing

of At this crossing, the advance of the product will be hindered by two man-made lakes that block the stream channel at both sides of The southern-most lake is 25 miles upstream of the confluence with After the confluence with

the drainage basin continues for approximately 1.1 miles to the crossing of From this point, continues in a southerly direction for approximately 1.3 miles to

residential developments to the east The northern-most point of is approximately 4.0 miles down gradient of

For purposes of this exercise, it is assumed that the balance of the product that does not escape Colonial’s facility will be collected by the tank dikes, catch basins, and drainage pipes and retained within the tank farm

Resources At Risk: Public and response worker safety would be the top priority concern for any spill scenario Colonial would quickly establish communications with the appropriate local emergency responders in the area of the tank farm The purpose of this communication would be to coordinate Colonial’s response to this specific incident with these agencies to best utilize available resources to protect the general public as the spill event progresses Specific actions will be discussed further under

“countermeasures” below

After leaving Colonial’s property and crossing under , the tributary of

r continues in a southerly direction through industrially-developed areas for 2.25 miles to the

the areas to the

and Golf Course, and residential developments to the east

As indicated in Section 9.06 of this Manual, (b) (3), (b) (7)(F)

Colonial Pipeline Company

WORST CASE DISCHARGE – SCENARIO

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There are no historical landmarks immediately threatened by this scenario

B Initial Incident Command Issues and Organization

The local Operations Manager would act as the Colonial OSC (On-Scene Commander) until relieved by either the Director of Operations or the Corporate Response Team Federal, state, and local agencies would assist and provide input to the spill effort Information that could be provided would include locations of rare and endangered species, historic sites, drinking water and industrial water intakes, and other environmentally sensitive areas Unless otherwise indicated by the Federal OSC, Colonial would follow the Colonial ICS for and the Southeast District In addition to personnel responding from the Southeast District, personnel would be immediately mobilized from throughout the Colonial system

Upon arrival onsite, Colonial would also work closely with officials from the EPA Region IV and the North Carolina Department of Environment and Natural Resources (NCDENR) As a first course of action, a joint review of Colonial’s response maps will re-identify natural resources, industrial, and residential developments threatened by the spill and which countermeasures would prove most effective in protecting these resources This activity includes protection, if possible, of endangered species, wildlife areas, and public recreation areas The U.S Fish and Wildlife Service office can provide information regarding known endangered species in the vicinity

For a tank failure occurring as described above, it would be clear from the outset that a prompt response from the entire area emergency response team would be appropriate Response personnel from the Gulf Coast District, the Northeast District, and the Atlanta Response Team would be mobilized This would result in an initial compliment of approximately 30-40 Colonial personnel onsite within the first five hours

of the response with an additional 5-10 support personnel mobilized from the Corporate Headquarters This compliment would be fully qualified to fulfill the various functions identified in the incident Command System in Section 4 of this Manual Colonial would also make back up and relief personnel available from other districts for a spill of this magnitude Colonial contracted OSRO’s would be mobilized as necessary

Issues Confronting Local IC:

Lack of precise volumes released from tank, volumes retained within dikes, and retention pond

(b) (3), (b) (7)(F)

(b) (3), (b) (7)(F)

(b) (3), (b) (7)(F)

Strategies

Decisions that must be made are:

Evaluate the actions that have been taken within an ICS structure and ensure that all work is completed

in a safe manner considering fire and explosion hazards associated with fuel oil and the current weather conditions

Determine Colonial resource needs and availability within the Southeast District, the adjacent Gulf Coast and Northeast Districts, and Atlanta office personnel Mobilize these resources in a timely manner to fulfill the 12 and 24 hour planning cycles

Locate additional areas for containment/recovering and protection besides those noted on Colonial response maps (SLD-1-11 and SLD-1-7)

Determine the number of additional spill response personnel needed for oversight, cleanup, containment, and countermeasures

Determine how much equipment will be necessary for containment, countermeasures, and cleanup actions

Decide who will provide the additional equipment

Prioritize response efforts for environmentally sensitive areas

Contractors

As part of the initial Notification Procedure, key area contractors would be notified within the first hour of the response For the given scenario a number of spill response contractors and tanker truck contractors would be mobilized and asked to send trained personnel and equipment to the closest staging location

in anticipation of a spill clean-up operation Using the “35-mph” rule for response contractors and allowing

an additional hour for equipment loading, it is estimated that most these resources would arrive within two to six hours of discovery

The following Oil Spill Response Contractors and other responders would be mobilized (response time): Marine Spill Response Corp (MSRC) – multiple locations (2 - 12 hrs.)

Hepaco, Inc – Raleigh, NC (3 hrs.)

Clean Harbors Environmental – North Carolina (3 hrs.)

The following Preventative Maintenance Contractors would be mobilized to assist in response and recovery efforts and pipeline repair:

ED Wallace Construction – Charlotte NC (3.5 hrs.)

Central Virginia Maintenance – Buckingham, VA (4 hrs.)

L.E Bell Construction – Heflin, AL (11 hrs)

This action could provide at least 200 HAZWOPER trained personnel as labor for the response operation,

as well as boom, skimmers, earth moving equipment, pipeline repair equipment, and other appropriate

Colonial Pipeline Company

WORST CASE DISCHARGE – SCENARIO

NC State Police and Local Fire Department

North Carolina Emergency Response Commission

Guilford County Local Emergency Planning Committee

As the response progressed and additional information as to the specific location of the emergency was discovered and/or reporting requirements were met, the following agencies would be directly contacted: U.S Department of Transportation, Pipeline and Hazardous Materials Safety Administration (PHMSA) Subsequent communications between specific Colonial response team members and these agencies would flow freely on an individual basis as is necessary

D Isolation

The affected tank would be isolated by Colonial’s operations personnel by closing the manifold valve to

after residual product remaining in the tank has been transferred to another tank This action would minimize the volume of additional product that could be released into the environment This action would isolate the tank and residual product to the greatest extent possible

An immediate assessment will be conducted to determine if an explosive atmosphere exists within the facility The spill site location is a considerable distance away from occupied buildings and the access road for In addition, the direction of spill travel is away from the facility and distillate products have a relatively high flash point of ignition Therefore, for the purpose of this scenario, it is assumed that the entrance road to the facility will remain open, and it would be unlikely that evacuation

of the facility would be necessary

Upon arrival at the area affected by the release, the first action by Colonial’s Emergency Response Team (employees and contractors) would be to assess the magnitude of the emergency in order to prioritize subsequent response actions and allocate available resources accordingly

Colonial employees or contractors would immediately begin monitoring explosive and oxygen concentrations in the atmosphere upwind and close to the spill site (if possible considering worker safety)

to establish appropriate hazard zones in accordance with OSHA regulations As the leading edge of the spill progressed away from the initial site towards the tributary of , further air monitoring would be required at all points where there would be a potential for public contact with the spill Access to these areas would be controlled accordingly

(b) (3), (b) (7)(F)

(b) (3), (b) (7)(F)

(b) (3), (b) (7)(F)

Spread of the spill off Colonial property would be towards the south into the tributary of

It is reasonable to assume that a significant portion of the spilled volume would not escape secondary containment and that a significant volume would be contained within the tank dike Due to the nature of the tank failure, and for the purposes of this exercise, it is assumed that a significant amount

of product ( would actually spill into this tributary It is very difficult to accurately estimate what quantities of product would escape containment and flow away from the facility

It is difficult to estimate the amount or speed at which the released product would migrate downstream

tributary, upstream of the confluence, would retain a significant amount of the product and would facilitate the deployment of equipment and containment activities

For purposes of this scenario, it is assumed that the leading edge of the spill would reach

(.4 miles down gradient of the tank) within five minutes of the release

The creek is a small, low gradient waterway with an estimated average channel velocity of approximately one mile per hour or less Due to the volume of the released product and the size of the stream, it is assumed that the initial velocity of product within the stream would be much higher than one mile per hour The following landmarks have been identified downstream of the release entry point:

A large volume of product was pooled on the ground inside the dike for

A significant volume of fuel oil has migrated into the adjacent dike to the north

A large amount of fuel oil has escaped the dike area and flowed overland into the small stream at a point downstream of the lake The leading edge of the released product has left the facility and reached the

An initial high priority activity would be to discuss with local emergency response agencies the need for immediate closing of

and the potential for evacuation of businesses and residents downstream to Colonial

Colonial Pipeline Company

WORST CASE DISCHARGE – SCENARIO

Because the purpose of this exercise is to discuss a scenario where a large volume spill occurs, and a fire event would reduce the total volume of spilled product, it is assumed for the purposes of this discussion that no accidental ignition of the spill occurs

Concurrent with actions to ensure the immediate safety of the general public, efforts would begin to stem the spread of the release and to minimize the release volume Response resources would be positioned and deployed at previously identified containment and recovery points In addition, reconnaissance personnel would locate additional containment and recovery points based upon actual conditions and communicate these locations to Planning

Containment/Recovery sites would be established at the lake downstream of at the

In conjunction with these activities, Colonial emergency responders would begin monitoring hazardous atmosphere levels (particularly explosive atmosphere) at the spill site to establish an appropriate hazard zone Air monitoring would be required at all points where public contact with the spill was likely and where deployment of resources would be necessary Access to these areas would be controlled accordingly

F Containment and Collection

Several factors would hamper efforts to collect and contain released product during the early stages of this release The combined effects of continuing rain, darkness, and higher flow conditions in the creek would make spill reconnaissance, assessment of suitable collection points, and deployment of equipment hazardous and difficult Further, historical cases of pipeline releases under similar conditions has shown that: 1) as the release travels downstream, the product tends to become agitated by the floodwaters to the point where it is indistinguishable from floodwaters heavy with sediments, and 2) the deployment of boom across even a moderate-sized stream during flood conditions is often only marginally effective in trapping product due to splash-over and underflow caused by swift currents Spill barges and deployment boats would possibly be used for recovery efforts in the

Product will enter the tributary of along the east bank and immediately be transported downstream towards This area is part of Colonial’s property

and the two culverts under it will help impede the flow of the product The product will cross the road and continue through the heavily vegetated channel and will enter the man-made lake north of

The lakes at both sides of this crossing are accessible Since the flow at this point

is slower, shore-to-shore boom placement, the blocking of the spillways, and product containment activities can be conducted without the need to improve equipment access to these areas

Harbor boom would be deployed in this area Deployment would be accomplished by utilizing small watercraft and shoreline personnel Maintenance and adjustments will be conducted as necessary Skimmers would also be utilized at this location along with direct recovery vacuum equipment and

pumping equipment

Frac tanks would be set up to serve as oil water separators The tanks could be used to provide “float time collection” prior to a sufficient number of tanker trucks arriving and during the ongoing shuttling of tankers throughout the first 90% of recovery efforts Additionally, these tanks could be used to maximize recovery efforts in the first few hours by the use of high-volume non-specific recovery pumps The tanks will allow large volumes of water to be removed from recovered oil common to the use of these non-specific pumps

Approximately 25 miles downstream of the second man-made lake south of , is the

downstream to the head of the stream is narrow and the flow velocity is estimated at one mile per hour or less

facilitate the establishment of a containment/recovery site utilizing multiple strands of boom deployed across the creek, skimmers, vacuum recovery, pumping equipment, and frac tanks for temporary storage The site is accessible to tanker trucks which would be employed to transport recovered product from the frac tanks back to storage at

Downstream on , skimming barges with product recovery storage capacity would be used

to recover product that escapes the containment booming at the

An additional containment/recovery site would be established at the bridge crossing of

Truck access appears reasonable and is assumed to be readily useable both from deployment and recovery efforts with no immediate improvements required Multiple strands

of boom would be deployed upstream and downstream of the bridge Frac tanks, skimmers, vacuum recovery, and pumping equipment would also be deployed at the site

As containment actions are being implemented, it will become necessary to evaluate on-going logistics for maintaining control of the plume, sustaining recovery actions underway, and implementing contingency measures to limit future exposure or release

Maintaining control of a plume involves careful consideration of oil collection rates and determining if such collection rates are exceeding recovery rates Adjustments in increasing recovery equipment is the first priority However, it is possible that timeline projections may prove that additional deployment of equipment would need to take place

Sustaining recovery actions involves having a place to store recovered oil in a location or locations of sufficient volume to keep up with recovery would have adequate capacity for this operation In addition, temporary storage tanks (frac) could be mobilized as required

Also important to sustaining recovery is personnel rotation and adequate lighting Generally, 30% of the work force should be sent back after the first six hours in order to preserve recovery rates on a 24 hour basis No more than 16 hours should be worked by any member of the Response Team This is especially important for the managers who are involved in logistics and coordinating response activities Adequate turn over meetings and supervisory overlap times are critical in maintaining recovery rates Contingency measures include installing shoreline protection boom to prevent the accumulation of oil in inaccessible areas and to mitigate the spread of further contamination in low-lying areas which pose

(b) (3), (b) (7)(F) (b) (3), (b) (7)(F)

(b) (3), (b) (7)(F)

(b) (3), (b) (7)(F)

Colonial Pipeline Company

WORST CASE DISCHARGE – SCENARIO

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difficulties for the implementation of recovery efforts All water intakes for commercial and industrial use should also have boom protection Marinas, docks, landings, etc., all represent a significant secondary risk to increasing cleanup effort and should be protected

Extensive efforts would be made to identify several locations where the release could be contained and collected, using the available resources identified above Due to the health hazards associated with distillate products, containment efforts would initially be focused at downstream locations prior to the arrival of the leading edge of the product

Information should continue to be gathered throughout the incident for operational purposes This information would be utilized in developing the 12 and 24 hour plans Some of this information might include:

Status of countermeasures completed by Colonial’s OSROs and support personnel

Amount of cleanup and containment equipment on scene

Amount of additional equipment needed and where it will be obtained

Prioritize environmentally sensitive areas for protective measures

Safety

Volume of product recovered at each collection point

Potential NRDA impacts/data needs

Problems that could be encountered include:

Unsafe working conditions due to hydrocarbon hazards and weather conditions

Contractor and Agency access to the facility, recovery points, and areas along the watercourses

Cleanup operations should involve all local, state, and federal agencies, the State and Federal Fish and Wildlife Agencies, and technical expertise should be solicited from USCG Strike Team

Methods of containment, countermeasures, and cleanup:

Mobilize personnel, vacuum trucks, frac tanks, skimmers, booms, boats, absorbents, temporary storage,

light towers, aircraft/surface surveillance, and debris disposal

areas for containment and recovery

Deploy boom to protect critical areas and recovery equipment as per reconnaissance input

Establish unified incident command center at

Safely recover and contain fuel oil at collection and recovery points recognizing health and other safety hazards

Clean stream and riverbanks as necessary/appropriate

Coordinate disposal and monitor sites

Collection of oil-laden debris

The following represents an approximate list of Colonial and response contactor personnel and equipment that could be employed on this spill:

HAZWOPER trained supervisory and technician level personnel

Vacuum trucks

Containment booms

Boom deployment boats

Miscellaneous air monitoring equipment, e.g., OVMs, OVA, CGIs, etc

Absorbent booms, pads, and sweep as needed

Tanker trucks

Barge-mounted modular skimmers

Drum, weir, and other light oil style skimmers

Diaphragm pumps and air compressors

(b) (3), (b) (7)(F)

(b) (3), (b) (7)(F)

(b) (3), (b) (7)(F) (b) (3), (b) (7)(F)

Colonial Pipeline Company

WORST CASE DISCHARGE – SCENARIO

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High volume 4” – 6” pumps

Colonial would obtain the following equipment on an as-needed basis:

Additional vacuum trucks

Frac tanks

Skimming equipment

Earth-moving equipment on an as-needed basis, i.e., excavators, bulldozers, etc

Personnel – All personnel listed in the Southeast District Emergency Response Plan would be mobilized Additional personnel would be mobilized from the adjacent Gulf Coast District, Northeast District, and Atlanta Office

Contracted OSRO’s will provide a significant portion of primary response equipment utilized in the response effort

Response time for all resources:

Colonial personnel on scene for containment would take action immediately District response personnel and OSROs would be onsite within 2 to 12 hours

Other District response teams, additional main office personnel and contractors

Northeast District (Response Zone 804) including tanker trucks and USCG-approved OSROs and contract personnel: 6 to 18 hours

Gulf Coast District (Response Zone 801) including tanker trucks, USCG-approved OSROs and contract personnel: 24 hours

NCDENR response team: 3 hours

USCG Strike Team: 6 hours

In summary, sufficient contracted USCG-approved OSROs and trained Colonial response personnel for

a sustained response will arrive on site within the required tiered response times

Potential Shortfalls

Underestimation of surface water flow impact and weather effect rendering boom deployment and skimmer operations ineffective

Short-term shortage of HAZWOPER trained personnel

Potential vapor and health hazards preventing effective recovery of fuel oil

Minimum Cleanup Time

One week for free product recovery

Four to six weeks for stream and riverbank/critical areas

Seven to twelve weeks for final cleanup

Greater than eight weeks for NRDA related activities

Colonial Pipeline Company

MINIMUM RESPONSE RESOURCES

Colonial Pipeline Company

NOTIFICATION & MOBILIZATION PROCEDURES

Colonial Pipeline Company 02.01.00 Notification & Mobilization Procedures Updated: February 2015

Page 1 of 12

Should an emergency occur, it becomes the responsibility of the employee who first becomes aware of

an emergency that is responsible for obtaining pertinent information and initiating the notifications as indicated on the "Emergency Notification Flowchart” found in Section 2.03 of this plan The employee should continue to follow the notification flowchart until a supervisor or manager relieves them of that responsibility

DEFINITION OF AN EMERGENCY

An emergency is an event that requires immediate response to mitigate the problem or conduct subsequent investigations An emergency may involve:

Injuries to an employee, contractor, or the general public

Significant property damage

Spilled product, a fire, or explosion

Local media attention

Required notification of local, state, and/or federal regulatory agencies

INFORMATION TO COLLECT

It is important to obtain pertinent information regarding the emergency The Initial Spill Information Report contained in Section 3.01 of this plan should be used to collect and document the desired initial information Field operators who receive pertinent spill related information may also document such information in the narrative log

TIME DESIGNATION

Any time designation established during verbal communications, emails, text messages, documentation, etc refers to local time for the location of the incident This should be clearly noted in all documentation (i.e., 1:34 pm local time)

INITIAL NOTIFICATION PROCEDURES

Agency Notifications

It is imperative that timely and proper agency notifications are made This includes notification of local police and fire departments Personnel responsible for making the required agency notifications are identified in the Emergency Notification Flow Chart An explanation of notification requirements of Federal, State, and Local agencies in the event of a petroleum release and/or emergency is located in Corporate Procedure 30 A list of other Federal, State, and Local agencies that may be of assistance is located in Section 5.04 of this plan

Immediate NRC Notification

Immediate notification to the National Response Center (NRC) is required for certain circumstances in accordance with 49CFR 195.52(a) These circumstances are if the event:

Caused a death or a personal injury requiring hospitalization;

Resulted in either a fire or explosion not intentionally set by the operator;

Caused estimated property damage, including cost of cleanup and recovery, value of lost product, and damage to the property of the operator or others, or both, exceeding $50,000;

Resulted in pollution of any stream, river, lake, reservoir, or other similar body of water that violated applicable water quality standards, caused a discoloration of the surface of the water or adjoining shoreline, or deposited a sludge or emulsion beneath the surface of the water or upon adjoining shorelines; or

In the judgment of the operator was significant even though it did not meet the criteria of any other paragraph of this section

INTERNAL NOTIFICATIONS & ACTIVATION OF SPILL MANAGEMENT TEAM(S)

The “Emergency Notification Flowchart” posted at each Colonial facility contains emergency telephone numbers for key personnel to initially notify It is the responsibility of the Incident Commander or his/her designee to decide whether or not to mobilize the District Spill Management Team and/or Spill Management Team The Spill Management Team is activated for significant spills or emergencies A roster listing the members of the Spill Management Team is contained in Section 5.01 of this plan

For significant events, the Incident Commander should discuss with the Crisis Management Team Leader the potential need to alert the Crisis Management Team The Crisis Management Team Leader decides

if the Crisis Management Team is to be activated

Group Notification System

Personnel with emergency response roles are activated using a group notification system The following two Group Notifications are used:

Group 4: Notifies Spill Management Team and other key personnel for significant spills/emergencies Group 8: Notifies District personnel with emergency response responsibilities

The groups are initially notified using a simultaneous combination of:

Text messaging to cell phones

Emails to PCs

Phone calls to cell phones and office phones

Messaging to the MIR3 phone application

Group 4 notifications are issued by the Control Center (at least initially) Group 8 notifications are normally originated by district personnel Initial group notifications may be short in content due to limited information being available at the time They primarily serve as an alert Follow-up group notifications should be made within an hour of the first alert to provide additional direction or the possibility of a stand-down

Group 4 and Group 8 responders are to follow the instructions contained in the text message

Responders with designated ICS positions are to connect with their section or unit leader for specific instructions on where and when to report Section and unit leaders will assemble their staffs

INSTRUCTIONS FOR SENDING GROUP NOTIFICATIONS

Colonial Pipeline Company

NOTIFICATION & MOBILIZATION PROCEDURES

Colonial Pipeline Company 02.01.00 Notification & Mobilization Procedures Updated: February 2015

Page 9 of 12

The initial message should provide the following information (if available):

Indication of whether the release is suspected or confirmed

General magnitude of release (no volume estimate should be included)

Type of product involved

Affected pipeline(s) and location of nearest city/airport

Note that there is a limit in the number of characters that can be included per text message It may require multiple text messages to convey the required information

Follow-up notifications may be used to provide more information as it becomes available, such as command post and staging locations

ALTERNATE NOTIFICATION METHOD FOR GROUP NOTIFICATIONS

In the event the MIR3 notification platform is unavailable for sending the Group Notification(s) as stated above, notification will be made by using the ICS phone tree This phone tree follows the ICS structure outlined in Section 4.02

The process of beginning this type of notification begins with the Incident Commander contacting the Documentation Unit Leader The Documentation Unit Leader will then contact each identified Section Chief The Documentation Unit Leader will confirm with the Incident Commander that all Section Chiefs have been notified

After each Section Chief is contacted by the Documentation Unit Leader, it is the responsibility of the Section Chief to initiate the notification process in their line of command by contacting the first individual listed in their line of command on the ICS The last individual in the line of command will contact their section chief to notify them the line of communication has been completed

NOTE: If at any time during the notification process, an individual is unreachable, the person attempting

to make contact, should skip this individual and contact the next individual in the IC structure in order to continue the notification process The person who is responsible for contacting the unreachable individual should continue to make contact until successful or contact the Section Chief for guidance as

to continue attempting notification or select another individual to fill the role

If the Spill Management Team is to be notified, the Incident Commander will contact the CCOM on duty The CCOM will coordinate contacting each Spill Management Team Member individually

Communication via the phone tree can be made by either text messaging or calling each individual If text message is the chosen means for the notification, the recipient of the text notification shall confirm receipt of the text message to the sender (Please note that if text messaging is chosen, text messages are limited to 100 characters and it may take several text messages to communicate the required information)

It is the responsibility of the individuals identified in the IC structure to maintain current contact information for the individual(s) they are responsible for contacting

NOTIFICATION DOCUMENTATION